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Grupo Fineco

PRI reporting framework 2020

Export Public Responses

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

Fineco continues to believe that responsible investing creates a positive impact in the environment and the society while generating higher return possibilities with less risk for our clients.

For the first time, Fineco´s Board of Directors (BoD)  EXPLICITLY approved ESG as one of the four strategic pilars for 2019-2021 strategic plan, with a wholistic RI policy starting with clear targets such as 100% of AuM to be under ESG integration by the end of 2021. Environmental, social and governance issues are considered key for the outperformance of our products and services and the BoD wanted to highlight its commitment and accountability to improve our investment services at the same time we generate a positive impact in the real economy. In fact, although labels are not perfect, there is an established calendar for all our funds being ESG labelled, together with a set-up plan for all employees to have ESG education and inclusion of ESG metrics in the reporting of our funds. The creation of an independent ESG committee and writing our proxy voting guidelines are also new from last year.

The publication of a Sustainability Annual Report and collaborating with public-private entities in fostering ESG world remain top priorities too.


01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

The main event in 2019 has been the explicit commitment of Fineco´s Board of Directors to achieve ESG integration in 100% of AuM by the end of 2021. With the launch of the new website (delayed by covid-19, which is generating urgent responses to critical issues), there will be a clear statement of the commitment (and therefore, accountability) of Fineco towards sustainable finance and also, a commitment to be sustainable towards all of our stakeholders.

In relation to investing, for internally managed funds, all of our analysts and portfolio managers have improved their approach towards integrating ESG metrics whether it is for equities or for fixed income worlds (sovereign, corporates and financials). We integrate external data we receive from MSCI ESG Research with internal indicators and with a new alert system for controversies that each analyst closely monitors in order for portfolio managers take quick decisions and avoid unnecessary risks (as it happened with Iberdrola, where we finally decided to sell the shares with the investigation to top executives)

In relation to equities, we have reached an agreement with Alembeeks to help us do the proxy voting. However, we first worked on our own to set up our own voting guidelines and then we signed the contract at the end of 2019 with Alembeeks so that we can learn and have better criteria for some topics where we might be less knowledgeable. Therefore, although we haven´t taken part in General Assemblies in 2019 (except for those companies where there was a premium to attend and where we held at least 1% of their market cap), during 2019 Fineco has decided to give important steps in the right direction in terms of active ownership and Fineco has started implementing it. In terms of engagement, we are analyzing how we can contribute to specific projects and we expect in 2020 to participate in at least one important engagement process.

In October 2019, we got our first fund ESG labelled by Aenor (we tried to do it with Le Label ISR but after several weeks, we were told that we needed to have our fund marketed in France -although it was UCITS fund- and that was too intense in resources since all the documents of the fund had to be translated to French and start a process of marketing it in France and it was too cumbersome). 

For externally managed funds, we have improved the questionnaire in our due diligence process in relation to ESG scoring to be more strict with the funds we include in our funds of funds. And for the fixed income fund ("Fon Fineco Renta Fija Internacional") where Pimco and Amundi are managing their own portfolios, we have increased the reporting requirements and the screening of their decisions and ESG investment processes. In 2020 we are planning to have this fund ESG labelled as well, which is going to give us a qualitative jump in our capacities and knowledge because it will aggregate different ways of understanding ESG world, different investment processes, different reporting metrics, etc. 

One key event in 2019 has been the creation of an ESG committee with independent members in order to monitor and foster Fineco´s efforts in providing more comprehensive and better ESG investment solutions to clients. The committee focuses on the monitoring of the integration of ESG variables in the investment process of the funds, checking how controversies impact the decision process in the funds, and proposing ESG education courses and requirements for the broad range of employees in Fineco, among other tasks.

Lastly, another new event in 2019 has been Fineco´s increasing effort in expanding the awareness of the importance of ESG criteria in the investment world. Not only we continued working with public and private entities in co-organizing the third edition of the "Biscay ESG Global Summit" and the second edition of the ESG summer programme at the Deusto Business School, but we took part (for the first time) as speakers in two international forums in London (June) and Amsterdam (October) organized by EthicalCorp, sharing panels with entities such as Blackrock, HSBC or corporates such as DSM.

01.6. Additional information [Optional].


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Additional information [Optional].

Generally speaking, Fineco does not publicly disclose investment policty components yet.

However, we would like to state that we will make available a document (it´s a short annual report) to the investors of our ESG funds where we summarize the whole year in terms of ESG issues, investment policy, controversy management and initiatives done by Fineco. It will be available on our new website (the launch has been delayed). Therefore, we can say it will be almost 100% public since it will be available to our clients (not open to general public) but that document could be at some point shared by a client to an outsider.

Unfortunately, the delay of the launch of the corporate website does not allow us to put any URL yet. In case we can provide the URLs at a later stage, we will be more than pleased. But we will like to firmly express our commitment to make more statements public in order to show our commitment towards ESG, sustainability and therefore, be accountable for it.

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

The Compliance department clears all the potential conflict of interest when investing in equities and fixed income.

All Fineco´s employees invest in Fineco´s funds so that there is no conflict of interest with our clients. In case there is an investment outside Fineco funds, it has to be pre-approved by Compliance department.

In case there is any suspicion that a trade could be related to market abuse, the trade is analysed and appoved/rejected by the Compliance department.

Any other trade that can generate a conflict of interest, Fineco follows legally approved procedures by the Spanish regulator.

In addition, there are frequent in-house courses and training sessions are conducted frequently for all employees

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)